- Introduction
- We are committed to safeguarding the privacy of our website visitors and service users.
- This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
- By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
- In this policy, “we”, “us” and “our” refer to Concept 4 Creative Limited. For more information about us, see Section 15.
- How we use your personal data
- In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
- We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
- We may process your account data (“account data“). The account data may include your name, address, telephone number and email address. The source of the account data is you or your employer. The account data may be processed for providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.
- We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.
- We may process information relating to transactions, including purchases of goods and services that you enter into with us and (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
- We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
- We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
- We may process electronic files received through our website. This data may include photographs, images, text files, logos and/or artwork. This data may be processed for orders placed on our website. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
- In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- In this Section 2 we have set out:
- Providing your personal data to others
- We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may disclose name, address, contact number and email address to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- When using Homework4 we may share your personal information with third party service providers who support the delivery of our service. These third party providers are:
Provider Purpose Google Integration with Google Drive through Google API Services to allow the sharing of files/documents from Homework4 Staff users to Homework4 Student users. Google Drive URLs are stored on your school’s Homework4 database.
We may use Google as a login method to authenticate a Homework4 user as a Student or Staff member. We use email addresses to verify this.
Microsoft Integration with Microsoft OneDrive through Microsoft Graph API to allow the sharing of files/documents from Homework4 Staff users to Homework4 Student users. Microsoft OneDrive URLs are stored on your school’s Homework4 database.
We may use Microsoft as a login method to authenticate a Homework4 user as a Student or Staff member. We use email addresses to verify this.
Wonde Limited Data partner facilitating connections to a School Student Information System (SIS) holding the personal data of Students, Parents and Staff.
We import this personal data to the Homework4 website/mobile application for viewing Staff timetables, Student timetables, classes and student groups, events, behaviour, achievement and assessment data.
Groupcall Limited Data partner facilitating connections to a School Student Information System (SIS) holding the personal data of Students, Parents and Staff.
We import this personal data to the Homework4 website/mobile application for viewing Staff timetables, Student timetables, classes and student groups, events, behaviour, achievement and assessment data.
Firebase Sending messages as push notifications for iOS app and Android app versions of Homework4. - In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- Retaining and deleting personal data
- Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Data Protection Officer (DPO).
- We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Security of personal data
- We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
- We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
- The following personal data will be stored by us in encrypted form: your name and contact information.
- Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
- You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- Amendments
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights of access, correction, erasure and restriction
- It is important that the personal information we hold about you is accurate and current. It is your duty to keep us informed if your personal information changes during your working relationship with us.
- You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
- We may withhold personal information that you request to the extent permitted by law.
- Under certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a “subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- request the transfer of your personal information to another party.
- If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO.
- Third party websites
- Our website includes hyperlinks to, and details of, third party websites.
- We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
- Our website and services are targeted at persons over the age of 18.
- If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Acting as a data processor
- In respect of the products and services detailed on our website we do not act as a data controller; instead, we act as a data processor.
- Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
- About cookies
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- We use cookies for the following purposes:
- analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _gat_UA-70459389-1, _ga, _gid, DYNSRV).
- We use cookies for the following purposes:
- Cookies used by our service providers
- Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
- We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/
- Managing cookies
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- Our details
- This website is owned and operated by Concept 4 Creative Limited trading as Homework4.
- We are registered in England and Wales under registration number 05059146, our registered office is at Lomeshaye Business Village, Turner Road, Nelson, Lancashire, BB9 7DU.
- Our principle place of business is at Lomeshaye Business Village, Turner Road, Nelson, Lancashire, BB9 7DU.
- You can contact us:
- by post, to the postal address given above;
- using our website contact form;
- by telephone, on the contact number published on our website from time to time; or
- by email, using the email address published on our website from time to time.
- Data protection officer
- Our Data Protection Officer may be contacted at info@homework4.co.uk